ncrc works for maryland consumers for research, education and advocacy. am also proud homeowner in baltimore city. thank you today. i appreciate all the work the bureau has done on these rules. homeownership as a now is a viable avenue for wealth building, especially for low and moderate income families. we know that these families use home-equity to increase the assets and to borrow against home equity, we know this is particularly true in communities of color. so we know that the work you're doing is incredibly important for all of our families come a special low and moderate income families. it's imperative that the mortgage lending rules adequately balance the needs of financial institutions and consumers. and it's important it opens up and provides more access to credit as well as clear and transparent standards for borrowers and lenders. however, our concern right now is that as written, the rules are too much to protect banks at the expense of working families. our concerns are that the safe harbor in the qualified mortgage rose provides too much o